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Tekce v. JRJ Investments, Inc.

United States District Court, D. Nevada

October 2, 2017

CIHAT TEKCE, individually, Plaintiff,
v.
JRJ INVESTMENTS, INC. d/b/a AUTONATION VOLKSWAGEN LAS VEGAS, a Nevada corporation, Defendant.

          JOSEPH A. GUTIERREZ, ESQ. STEPHEN G. CLOUGH, ESQ. MAIER GUTIERREZ & ASSOCIATES ATTORNEYS FOR PLAINTIFF CIHAT TEKCE

          PATRICK H. HICKS, ESQ. TIMOTHY W. ROEHRS, ESQ. LITTLER MENDELSON, P.C. ATTORNEYS FOR DEFENDANT JRJ INVESTMENTS, INC. D/B/A AUTONATION VOLKSWAGEN LAS VEGAS

          STIPULATED PROTECTIVE ORDER

          Cam Ferenbach United States Magistrate Judge

         Plaintiff CIHAT TEKCE and Defendant JRJ INVESTMENTS, INC. d/b/a AUTONATION VOLKSWAGEN LAS VEGAS, by and through their undersigned counsel, hereby stipulate that in order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the parties agree as follows:

         1. Any party may designate as “confidential” (by stamping the relevant page or labeling the item or as otherwise set forth herein) any item, document or response to discovery, which that party considers in good faith to contain information involving: personal and confidential information of third-parties or non-parties; trade secrets; or sensitive and/or confidential business or financial information of the parties, subject to protection under the Federal Rules of Civil Procedure or Nevada law (“Confidential Information”). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.

         2. A party may designate documents, items, or information disclosed during a deposition, in response to written discovery as “confidential” by so indicating in said response or on the record at the deposition and requesting the preparation of a separate transcript of such material. Additionally a party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as “confidential” information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all parties shall be responsible for making all previously unmarked copies of the designated material in their possession or control with the specified designation.

         3. All Confidential Information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party to whom the information is produced solely for the purpose of this case.

         4. Except with the prior written consent of other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:

(a) counsel for the respective parties to this litigation, including in-house counsel and co-counsel retained for this litigation;
(b) employees of such counsel;
(c) any officer or employee of a party, to the extent deemed necessary by Counsel for the prosecution or defense of this litigation;
(d) consultants or expert witnesses retained for the prosecution or defense of this litigation, provided that each such person shall execute a copy of the Certification annexed to this Order as Exhibit “A” (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by opposing counsel during the pendency or after the termination of the action only upon good cause shown and upon order of the Court) before being shown or given any Confidential Information;
(e) any authors or recipients of the Confidential ...

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